The Collection and Use of Personal Information
The following list describes the limited categories of Personal Information we may have collected about you in the past 12 months. As described above, we collect these categories of Personal Information from you directly, automatically from your interactions with us, or from third party sources. We collect this Personal Information for the business and commercial purposes of providing our services to you or otherwise for the management and administration of our website and business, to evaluate your job application or for purposes of your employment, communicating with you about our products and services, for fraud detection and prevention and other security purposes, to comply with legal requirements, enforce our policies or contracts, or otherwise to protect our rights and interests.
Identifiers, such as name, email address, address, phone number, facsimile number, IP address, social security number or other similar identifiers.
Characteristics of protected classes and demographic information, such as age, sex, and marital status. Note that we do not collect this information from job applicants.
Commercial and financial information, such as records of personal property, products or services purchased, obtained, or considered, information on investments, assets, net worth, tax status, holdings, account balances, transaction history, bank account details, wire transfer instructions.
Internet or other electronic activity information, including information regarding an individual’s interaction with a website or mobile application, emails sent and received.
Audio, electronic, visual, thermal, or olfactory information, such as copies of drivers’ license, passport or other photograph identification, or information from security cameras in certain of our facilities that deploy them.
Professional or employment-related information Education information
Inferences drawn from any of the information identified above, to create a profile reflecting an investor’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Information Collected and Stored Automatically
The Site automatically collects some technical information from you when you visit the Site in order to give you the best possible experience. The Site uses web measurement technology (e.g., Google Analytics) to automatically track how visitors interact with the Site, including where they came from, what they did on the Site and whether they completed any pre-determined tasks while on the Site. Aggregate data is used to help improve our user interface and diversify our content offerings to meet the needs of our customers, track operational problems, prevent fraud, and improve the effectiveness, security, and integrity of the Site. This information is retained in accordance with the CAIS data retention policy. For each page that you visit, we collect and store information about your interactions with our site, including the following technical information:
Date and time of access
URL address of the Site webpage visited
Internet domain and IP address from which our website was accessed
Type of browser and operating system used to access the Site (if provided by the browser)
URL address of the referring page (if provided by the browser)
Completion or success status of the request for a webpage or other on-line item
File size of the webpage visited
This information is used to help us make the Site more useful for you. With this data we learn about the number of visitors to our Site and the types of technology our visitors use. In the password protected portion of the Site, CAIS maintains the right to track and store all actions which are performed during each visit; this is subject but not limited to products that were viewed and documents accessed; other than our third party service providers that support our site processes, we do not share this data with anyone outside CAIS unless necessary for law enforcement purposes or to otherwise comply with applicable law or to protect our rights and property and enforce our terms.
Information That You Provide Voluntarily
Cookies and other Tracking Technologies
We use two types of cookies. A session cookie is a line of text that is stored temporarily in your web browser’s memory cache and will expire when the browser is closed. A session cookie is not placed on any hard drive, and it is destroyed as soon as you close your browser. We may use session cookies to facilitate certain site functionality and features. A persistent cookie is saved to a file on your hard drive and is accessed whenever you re-visit the website that put it there. This lets that website remember what you were interested in the last time you visited. We use persistent cookies to enable analytics (e.g., Google Analytics) to differentiate between new and returning Site visitors. Persistent cookies remain on your computer between visits to the Site until they expire.
CAIS may utilize third party services to enhance its distribution of data and information (e.g., videos) through links from the Site. A persistent cookie may be set by such a third-party provider when you click on the provider’s link in order to access CAIS data (e.g., play a video).
By default, persistent cookies and web measurement technologies are automatically used when you visit the Site. We may allow third party ad serving companies or ad networks to display third party advertisements on the Site. Some of these companies may place a persistent cookie in order to recognize your computer each time they send you an online advertisement. Thus, these companies may compile information about where you are using your computer, where you saw their advertisements, and which ads you clicked on. This information allows these companies to deliver targeted advertisements that they believe will be of most interest to you. We do not have access to the cookies that may be placed by these companies. If you are interested in learning more about and/or opting out of online advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as www.youradchoices.com or aboutads.info. Please note that our site does not respond to browser “Do Not Track” signals.
Sharing of Information
CAIS does not sell your Personal Information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share Personal Information with certain third parties without notice to you, including those set forth below. For each of the personal information categories listed above, we may share this information with other entities and affiliates for business or commercial purposes.
Agents, Consultants and Related Third Parties:
We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function. We require such third parties to maintain the confidentiality of such information and use such information only as necessary to provide us with designated services. We may also share information with our affiliates that assist us in the management and administration of our business.
We may aggregate your Personal Information with Personal Information of other users of the Site and disclose such information in a non-personally identifiable manner to advertisers and other third parties for marketing and promotional purposes. In these situations, we will not disclose to these entities any information that could be used to identify you or your clients personally.
We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) at the request of governmental authorities or other third parties conducting an investigation (c) to detect and protect against fraud, or any technical or security vulnerabilities, (d) to respond to an emergency, (e) act in urgent circumstances to protect the personal safety of users of the Site or the public, (f) protect against legal liability, (g) or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites, or the public.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets
CAIS may also use online survey instruments to obtain feedback on your experience with the Site. The survey initiation pops up for a random sample of visitors, is voluntary and does not collect personal information. If you decline the survey, you will still have access to the same information and resources of the Site as those who do take the survey. The survey reports are available only to the Site’s managers and other staff who require this information to perform their duties. CAIS retains the data from the survey results in accordance with its data retention policy.
Social Media and Third-Party Websites
CAIS uses some social media tools and websites to interact with its customers and resource partners. Social media websites are used to publicize CAIS programs and services and engage with members of the public. CAIS does not use third party websites to solicit and collect personal information from individuals. Any personal information collected by a third-party website will not be transmitted to CAIS unless required for law enforcement purposes or as otherwise permitted by law. CAIS’ privacy and other web policies do not apply to these third-party sites and we encourage you to read the policies of the third-party site when deciding whether to use it.
Site Security and Safeguarding of Information
CAIS maintains reasonable administrative, technical, and physical policies, procedures and safeguards designed to assist us in protecting the Personal Information we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. These measures include computer safeguards, secured files and buildings, and employee background checks. For Site security purposes and to ensure that this service remains available to all users, this computer system employs commercial software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. The CAIS computer system is protected by firewall and anti-virus software and employs encryption technology for data storage. CAIS networks also employ automated network and server monitoring. All major components of the application and hardware architecture have been designed for automatic or semi-automatic rollover in the event of a failure. We take commercially reasonable steps to protect Personal Information and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Information to us or to any other party via the Internet or e-mail.
Other Terms and Conditions
We are also committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests, please contact us at (212) 300-9350 or contact [email protected]
Questions or comments regarding the Site, including any reports of non-functioning links, please contact us.
California Privacy Rights: This California Privacy Rights and Disclosure section addresses legal obligations and rights specified in the California Consumer Privacy Act, or CCPA. The CCPA applies to businesses “doing business” in California and to California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers. CAIS frequently operates in a business to business (“B2B”) context and as a service provider to other companies, and it is subject to the Gramm-Leach-Bliley Act (“GLBA”). Employee data, B2B data and data subject to GLBA are exempt from many of the CCPA’s requirements.
Your California Privacy Rights to Request Disclosure of Information We Collect and Share about You
California residents may have the right to request certain information about our practices with respect to Personal Information. In particular, you may have the right to request the following:
The categories of your Personal Information that we’ve collected and disclosed to third parties.
The specific pieces of your Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purposes for which we collected or sold Personal Information.
The categories of third parties with which we shared Personal Information.
As noted above, we do not and will not sell your Personal Information to third parties.
How We Will Handle a Request to Exercise Your Rights
To exercise your CCPA rights with respect to this information, please email us at [email protected], or contact us at (212) 300-9350. These requests for disclosure are generally free, and we will not discriminate against you for exercising your rights. However, please note that, in addition to certain exceptions that may apply to data, CAIS frequently acts as a service provider to another business with respect to your information. Accordingly, some requests might relate to data where CAIS is not the business determining how your information is collected, used, and/or shared, and cannot directly respond to your request.
We will provide a substantive response to your request generally within 45 days from when we receive your request, although we may take longer to process your request under certain circumstances. Before responding to your request, we will need to verify your identity based on information we maintain about you. The specific verification data we may request will vary depending on your relationship with us and the nature of your request. You may place a request through an authorized agent; however, you will also need to verify the agency request as well. Requests that relate to a household must be placed through a verified request from each member of the household. For any request, if we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.